U.S. Proposed Regulations on Ownership Attribution for Purposes of Determining Whether a Person Is Related to a Controlled Foreign Corporation
The U.S. IRS and Treasury have released proposed regulations on Ownership Attribution for Purposes of Determining Whether a Person Is Related to a Controlled Foreign Corporation; Rents Derived in the Active Conduct of a Trade or Business (REG-125135-15). The regulations are to generally apply for taxable years of CFCs ending on or after the date they are published as final regulations, although…
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